"our" are references to SplitPass, Inc. and any group companies involved in providing the Services.
When you use our Services, we collect personal information about
we collect, how we use it and with whom it is shared.
the world as required by local laws. If you are accessing the Services in the
European Union and the United Kingdom, then you will have additional rights
is divided into the following sections:
How to contact us
we use your personal information, you may contact us by email at
As used in
information that specifically identifies an individual (such as a name, user
name, e-mail address, postal address, phone number, credit card details, or
account details) or information about
individual that is directly linked to information specifically identifying an
individual. If you are using the Services in the European Union and United
Kingdom, then personal information may also include additional data that could
identify you or be indirectly linked to you, such as some aggregated data, your
location, device id and the way that you use the Services. We have explained
more about the information we collect about you in the section below.
Personal information which you provide to us, or which is provided
to us by third parties.
The following personal information about you is provided to us
either by you, or by third parties:
Information that you have provided to us or one of our third-party
suppliers, such as your name, email address, telephone number, postal address,
date of birth, payment information, credit card number, expiration date,
authentication code, and similar information. This includes credit card
information you provide when provide an image of your credit card to us using a
Information you provide to us when you communicate with us as part
of the Services, for example when you call us, text us, or email us.
Information about you that you have made publicly available and
which we use as part of the Services.
Information about you which we have obtained from certain third
Information about the total value of the bookings you have made.
Information about your location. We use this information to provide
our Services to you, to improve our Services, and to send you information about
products and services you may be interested in.
You can decide not to provide certain personal information.
However, if you choose not to provide it, you may not be able to use our
We collect certain information about you automatically.
When you use our Services, some information is also automatically
collected, such as:
Information about other websites you have visited (for example,
the address of a referring website) before using the app;
Information about how you use our app (for example, how long you
spend using it, how often, and when you last used it).
Information about your location.
We may collect certain technical and device-specific information,
such as your IP address, your hardware model, operating system version, unique
device identifiers, and mobile network information including your phone number.
Other personal information from third parties. For example,
information obtained when you use social media accounts.
We may also automatically collect certain information through the use of "cookies." Cookies are small data files stored on your hard drive at the request of a website. Among other things, cookies help us
to improve our Services and your experience. If you wish to block, erase, or be warned of cookies, please refer to your browser manufacturer to learn about these functions. However, if you choose to remove or reject cookies, this could affect
our ability to provide our Services to you.
We may also employ the use of anonymous identifiers, which are
random strings of characters that are used for the same purposes as cookies on
platforms, including certain mobile devices, where cookie technology is not
We may use web beacons or similar technology on our Services. Web
beacons are small, invisible graphic images that may be used on our Services or
in emails relating to our Services to collect certain information and monitor
user activity on our Services, such as to count visits, understand usage
effectiveness and to tell if an email has been opened and acted upon.
We use personal information we collect for the following purposes:
To enable us to provide our Services (e.g. to take payment from
you or make a booking, or to send you booking confirmations via email or text
To request feedback and to otherwise contact you about your use of
To respond to your emails, questions, comments, requests and complaints, and to provide customer service.
To monitor and analyze how you use our Services, for example, how long you spend using our app, how you use our app, your usage and trends.
To personalize and improve our Services, and our users' experiences with our Services (such as providing content or features that match interests), and to increase our Services' functionality and user friendliness.
To provide you with marketing messages, news and information about
events, offers, promotions and services we think will be of interest to you (if
you do not wish to receive these messages, you can unsubscribe by following the
instructions at the bottom of the message).
To send you confirmations, updates, security alerts and support
and administrative messages, and otherwise facilitate your use of, and our
administration and operation of, our Services.
To notify you about important changes to our Services.
other policies or agreements.
To investigate and protect our users from fraudulent, abusive,
inappropriate, or unlawful use of our Services.
For other purposes which are explained to you at the time we
collect your personal information.
We share your personal information with the following third
parties, which may vary from time to time and may be different according to
where you are located when you access the Services:
Gyms - In order to provide our Services, we share your personal
information with Gyms you have booked, or with other third parties who carry
out Services on the Gyms' behalf.
Other users - If you choose to include personal information (such
as your email address, photo or other details) in your public profile, this may
be viewed by others who use our Services. If you choose to participate in a
discussion forum, your IP address may be shared with forum moderators.
Sometimes information you choose to share will be available to other users and
in some cases may be publicly available (for example, where you share personal
information as part of a review, photo submission or similar).
Our marketing and sales partners - We share your personal
information with our marketing and sales partners, who help us manage our
advertising, and enable us to send you information about products and services
you may be interested in. These partners help us to manage our customer
information and personalize emails. We may share your name, email address,
information about how you use the internet and our Services, information about
your device (such as your device ID, operating system and browser) and information
about your location.
Third-party service providers - From time to time, we may need to
share your personal information with certain third parties so that they can
perform services on our behalf. This may include payment and credit card
information, your name and address, details about your invoice, details of your
account with us, location, and information about the device you are using to
access our Service (such as your device ID, operating system and browser,
application and service logs, and information about how your use and interact
with our app). Typically, our third-party service providers help us by carrying
out data analytics, providing booking and general customer support, processing
payments, supporting email or IT services (for example, backing up our data),
or carrying out similar activities. We also share your personal information
with a range of other third-party service providers who help us provide our
Services, improve your user experience, develop our business, or help us
anticipate and fix any problems with our Services.
Third parties requiring information for legal reasons - We may
share your personal information with others if the law requires us to, or if we
think it is necessary to comply with the law. We may also share your personal
information if we need to do so to protect or defend our legal rights, or those
Third party investigators, authorities or law enforcement bodies -
We may share your personal information to investigate and protect our users
from fraudulent, abusive, inappropriate, or unlawful use of our Services.
Potential buyers or investors - In the unlikely event that we
wished to sell our business, we may need to share your personal information
with a potential buyer or an investor.
Group companies - We share your personal information with members
of our group of companies where required for business operational reasons.
If you are accessing our Services in Europe, then we are required
to ensure that we only process your personal information where we have a legal
basis to do so. When we process your personal information, we will only do so
where at least one of the following applies:
We need to use your personal information to perform our responsibilities
under our contract with you (e.g. processing payments for and providing our
It is in our legitimate interests to use your personal information
in certain circumstances. For example, it is in our legitimate interests to use
your personal information in connection with our Services; to improve our
Services; to ensure that our Services are secure; to, tell you about changes to
our Services; to tell you about new services or products we are offering; for
business reasons (for example to develop our business or if we are thinking of
selling our business); to tell you about offers or promotions we are running;
for operational purposes.
Sometimes we may ask for your consent to use certain types of
personal information (e.g. by asking you to tick an online box). In these
circumstances, your consent will be our legal basis for processing your
personal information. If you have provided consent, you may withdraw it at any
time. You may do this where we give you the opportunity to do so, or by
contacting us using the contact details above. For example, we may ask for your
consent to pass your personal information to third parties who may send you
information about products, services or offers you may be interested in.
In general, we will only keep your personal information for as
long as it is necessary to fulfill or achieve the above
mentioned purposes. Alternatively, we may continue to use your personal information in anonymized form. When you close your account with us, we will generally delete your personal information. Sometimes, however, we may keep
your personal information after you have closed your account. For example:
We may retain personal information about how you have used our
Services in anonymized or aggregated form after you have closed your account
with us so we can analyze how you have used our Services and improve users’
We may also retain your personal information after you have closed
your account so that we can send you information about products and services we
think you may be interested in. You can "unsubscribe" to receiving
We may retain your personal information in order to protect our
legal rights, or those of third party, or to comply with the law.
Whenever we transfer your personal information out of the EEA, we
will comply with applicable data protection law. Some of the mechanisms we may
choose to use when undertaking an international transfer are:
The transfer of your personal data is to a country that has
officially been deemed to provide an adequate level of protection for personal
data by the European Commission.
We may use specific contracts approved by the European Commission
which give personal data the same protection it has in Europe (called the “EU
Where we use providers based in the US, we may transfer data to
them if they are part of the Privacy Shield which requires them to provide similar
protection to personal data shared between the Europe and the US. If the
provider is not EU-US Privacy Shield certified, we may use the EU Model
Many of our external third-party providers are based outside the
EEA, so their processing of your personal data will involve a transfer of data
outside the EEA.
Our Services may contain links to other websites. Any personal
information you provide on the linked pages is provided directly to that third
responsible for the content or privacy and security practices and policies of
these websites or any other websites that are linked to/from our Services. We
encourage you to learn about their privacy and security practices and policies
before providing them with any personal information.
You may "opt out" of receiving marketing or promotional
messages from us by following the instructions in those messages. If you opt
out, we may still send you non-promotional emails, such as emails about your
account or our on-going business relations.
You may correct, amend, or update your personal information by
editing your profile on the app.
If you need help or have questions, please contact us using the
details above. We will consider all such requests and provide our response as
soon as we can. Please note, however, that personal information may be exempt
from such requests in certain circumstances, which may include needing to keep
processing your personal information for our legitimate interests or to comply
with a legal obligation. Please note that we may request you provide us with
information necessary to confirm your identity.
If you have any complaints, queries or questions about how we use
your personal information, you may contact us using the contact details set out
above. We will then get in touch with you to see how we can help. If you have a
complaint about how we use your personal information, we would always prefer
you to contact us first. However, you may also make a complaint to the relevant
data privacy regulator if you wish to do so. Please let us know if you are
unsure about how to get in touch with the data privacy regulator.
information will be used.